Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
ITAT allowed the appeal, holding that s.115BAB (concessional tax on income of new manufacturing domestic companies) and related adjustment provisions are inapplicable where the assessee has not commenced business and has no taxable income. The Tribunal found no profit even after adjustments, and therefore there was no basis to grant or deny a concessional rate, nor to invoke rules concerning shifting of profit or specified domestic transactions for the year under review. Consequently, no adjustment under the concessional-tax provisions was warranted and the ground raised by the assessee was allowed.
ITAT allowed the appeal, holding that s.115BAB (concessional tax on income of new manufacturing domestic companies) and related adjustment provisions are inapplicable where the assessee has not commenced business and has no taxable income. The Tribunal found no profit even after adjustments, and therefore there was no basis to grant or deny a concessional rate, nor to invoke rules concerning shifting of profit or specified domestic transactions for the year under review. Consequently, no adjustment under the concessional-tax provisions was warranted and the ground raised by the assessee was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
